In the first part of this post, we began discussing the issue of worker classification for purposes of paying (or avoiding) payroll taxes. The issue of worker vs. contractor has been around for years, but is as timely as ever. As we noted, this is because revenue agencies have been […]
Author: Lawrence Brown
At an annual Offshore Alert conference, the director of the IRS offshore voluntary compliance initiative revealed that the IRS recently issued John Doe summonses to seven more foreign private banks. While he did not reveal which banks the summonses were issued to, he did say that they were not limited […]
IRS Criminal Investigation (CI) released its annual report, which details statistics for the 2014 calendar year, as well as its current enforcement priorities. The report yielded some interesting findings. As expected, the budget cuts that have afflicted the IRS have also affected CI, with the overall number of investigations initiated […]
Worker classification and its connection to payroll taxes is a thread we have been following for quite some time in this blog. In the last few years, tax authorities have put considerable pressure on employers regarding the possible misclassification of employees as contractors in order to avoid payroll tax obligations. […]
In the first part of this post, we discussed the possibility of getting a preliminary (but not binding) ruling from the IRS about an upcoming transaction with significant tax consequences. As we explained last week, a private letter ruling may be used for that purpose. But what about a transaction […]
If you have a complicated transaction coming up for your business, there may be tax consequences that you would like to get more clarity on before moving forward. Or, you may have a tax question from your past that you’d like to resolve. In such cases, is it possible to […]
Due to budget cuts in recent years, the IRS has downsized its employee headcount significantly. But the agency’s pursuit of criminal investigations has been going up, not down. This is a story we’ve been following for some time. We discussed it at length a couple of years ago in an […]
Facing billions of dollars in potential fines at the hands of U.S. authorities, Swiss banks are scrambling to convince their American clients to voluntarily disclose their accounts to the IRS. Long known for its secrecy, Switzerland’s banking industry has been turned upside down due to an ongoing U.S. onslaught against […]
As the Department of Justice continues its efforts to prosecute individuals involved in offshore tax evasion, approximately two dozen indicted Swiss bankers remain fugitives in Switzerland. Although the United States and Switzerland have an extradition treaty, Switzerland will not extradite individuals accused of tax crimes. While these individuals are free […]
In the first part of this post, we posed the question of how far the IRS can go back into your past when conducting tax audits. As we noted, the IRS by no means has a blank check to do this. Generally the limitation is three years, or up to […]